Important Drawback Compliance Reminders: AP Privilege Revocations for Noncompliant Claimants

U.S. Customs and Border Protection (CBP) recently released CSMS #61941423 – Drawback Compliance Reminders stating that they are enforcing compliance for drawback claimants by revoking Accelerated Payment (AP) privileges when they deem a claimant is noncompliant with drawback regulations and procedures.

Compliance has always been paramount in a drawback program, but this CSMS adds a heightened level of warning for claimants that needs to be taken seriously. While CBP has confirmed the list of issues on the CSMS is their primary concern and there are cases where the claimants may be doing these things intentionally, it’s important to note that what CBP deems as “good cause” may also be an unintentional error by the claimant.

Accelerated Payment privileges usually take more than 90 days to obtain and have proven more difficult to reinstate after a revocation. If a claimant loses their AP status, that means that any claims they file will not be paid until liquidation—sometimes up to four years after filing. This can have a significant impact on expected refunds. Even if filing with a drawback provider, it is the claimant’s responsibility to supervise their data to ensure that it is accurate as provided, supportable with documentation, and used correctly for drawback claim filings. All drawback claimants need to exercise increased caution and scrutiny of all data that they are using for claims, or else risk the potential to have drawback privileges revoked by CBP.

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